Compliance Training Program
Compliance Management School (CMS)
Program OverviewThe Compliance Management School (CMS) is the final school attended by pre-commissioned compliance examiners prior to participating in the commissioning process. Participants are required to analyze a case study bank’s prior examination findings, its policies, practices and procedures, and relevant documentation to evaluate all facets of the bank’s Compliance Management System. Using perception, judgment, and decision making skills each participant is responsible for determining the condition of each element of the bank’s Compliance Management System, assigning an appropriate overall examination rating, and providing written support for their conclusions. Participants complete and receive individual feedback for several exam-related activities including an Assessment of Risk of Consumer Harm (ARCH) Memorandum, a consultation memo, a Report of Examination, and an Exit Meeting.
Key ObjectivesUpon completion of this course, participants will be able to:
- Analyze information to determine a bank’s compliance with a variety of rules and regulations.
- Draw meaningful conclusions.
- Evaluate a case study institution’s compliance management system.
- Support conclusions verbally and in writing.
DurationThis is a three-week course.
Instructional FormatPre-course work (Independent Self Study), facilitated classroom discussion/lectures, small group activities, and in-class project.
This course is designed for pre-commissioned compliance examiners who generally have 18 to 24 months of experience in compliance examinations after entering the compliance discipline. There should be a minimum of six months after attending Community Reinvestment Act School.
This course is open to appropriate staff of the FDIC and partner government regulatory agencies. This course is not open to the public or staff of private banks.
PrerequisitesPrior to attending the Compliance Management School participants must have satisfactorily completed the Fair Lending School and the Community Reinvestment Act School. Additionally, participants must have satisfactorily completed two acting examiner-in-charge assignments in accordance with the Acting EIC lesson plan contained in the Compliance OJT Reference Guide.
Pre-Course AssignmentThe assignment requires completing pre-exam planning (analyzing data received from a bank based on a CIDR request, reviewing past exam reports, reviewing correspondence file information, and reviewing the bank’s case report) and preparing an Assessment of Risk of Consumer Harm (ARCH) Memorandum for the case study bank. Thorough knowledge of all bank and prior exam related information contained in the pre-course materials is essential for success in the course.
Official TimeThe Division of Depositor and Consumer Protection (DCP) has authorized 40 hours of official time to complete the pre-course assignment.
Post-Course RecommendationParticipants should be scheduled to perform an acting Examiner in Charge assignment as soon as possible after completing this course to reinforce the skills acquired.
Post-Course FeedbackSummary Evaluation Forms, which provide comprehensive analysis for each of the critiqued assignments during the school are sent to the participant's supervisor approximately thirty days after the conclusion of the school. Additionally, participants receive feedback on their written products from a writing professional associated with the school; this feedback is also provided to the supervisor.
CreditsContinuing Education Unit (CEU): 10.5
Continuing Professional Education Unit (CPE): 126.0
For information regarding administrative policies such as complaints and refunds, please contact Corporate University, Attn: NASBA Representative Ava Livas, Room A-3025, 3501 North Fairfax Drive, Arlington, VA 22226 (703) 562-2463.
FDIC is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org.
The FDIC has been approved as an Authorized Provider by the International Association for Continuing Education and Training (IACET) (www.iacet.org), 1760 Old Meadow Road, Suite 500, McLean, VA 22102.